September 13, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Exemption Request Pursuant To Section 333 of the FAA Modernization and 

Reform Act of 2012

Name and Address of Petitioner

James G. Compton, Member

Digital-Hover LLC

4422 Oliver Place

Amarillo, TX

806-881-1836

james@digital-hover.com

Introduction

As set forth herein, to commercially operate small Unmanned Aircraft Systems (UAS) 

safely and legally in the National Airspace System (NAS), James G. Compton of DigitalHover, LLC, 4422 Oliver Place, Amarillo, Texas, seeks an exemption from Federal 

Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization 

and Reform Act of 2012.

Section 333 states that the FAA may issue a certificate of waiver upon a finding that a 

type of UAS, as a result of its size, weight, speed, operational capacity, proximity to 

airports and populated areas, and operations within visual line of sight do not create a 

hazard to users of the NAS or the public or pose a threat to national security. The grant of 

such an exemption is consistent with Congress’ intent, reflected in Section 333, that safe 

systems be permitted in the national airspace prior to the issuance of final regulations 

governing general use of these systems.

Being “unmanned aircraft and associated elements, including communication links and 

the components that control the unmanned aircraft that are required for the pilot in 

command to operate safely and efficiently in the national airspace system,” DigitalHover’s UAS meet the Section 331 definition of “small unmanned aircraft.”

Section 332 provides for such integration of civil unmanned aircraft into our national 

airspace system as it is in the public’s best interest to do so. We would like to operate our 

small UAS(s) prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft, thereby providing direct experience and valuable 

information for formal regulation.
Digital-Hover intends to use small UAS to provide aerial photography and videography 

services to businesses, organizations, and community members. See the Public Benefit 

section of the document for more details. More specifically, we intend to:

 Enable businesses to improve marketing and outreach through the use of state-ofthe-art aerial photography and videography

 Help to inspect buildings and structures, and map landscapes in a safe, costeffective manner 

 Provide economic stimulus and public benefit by providing an effective means by

which companies or individuals can use up-to-date, high-quality photos and 

videos to learn about properties, neighborhoods, and communities

 Help communities realize economic benefit by encouraging public participation 

and encouraging tourism; by showcasing community buildings and landscapes; 

and by documenting community events in low-cost ways not previously available 

to them 

 Increase awareness/knowledge of the amenities of a local area by the general 

public and by visiting tourists

 Provide non-profit organizations as well as schools and universities and local 

municipalities ways to showcase facilities, document events, and educate the 

public

 Aid in search and rescue operations and accident investigations

We understand that we are entitled to submit a Petition for Exemption if we believe that 

following a rule will burden us, we can provide a level of safety at least equal to that 

provided by the rule, and our request is in the public interest. Therefore, we seek relief 

from the following sections of the current regulations:

14 CFR 21 subpart H – Certification procedures; Airworthiness Certificates

14 CFR 45.23 – Display of Marks

14 CFR 61.113(a) & (b) Private Pilot Privileges and Limitations

14 CFR 91.105 Flight crewmembers at stations

14 CFR 91.109(a) Flight instructions

14 CFR 91.119(c) Minimum safe altitudes

14 CFR 91.121 – Altimeter settings

14 CFR 91.151(a) – Fuel Requirements for Flight in VFR Conditions

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

14 CFR 91.405(a) 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2) Maintenance 

required; Operation after maintenance, preventative maintenance, rebuilding or 

alteration

14 CFR 91.417(a) & (b) Maintenance Records

14 CFR 91.7(a) – Civil Aircraft Airworthiness

14 CFR 91.9(b) – Civil aircraft flight manual, marking, and placard requirements.

This application is similar to many which have received FAA approval. As stated in 

Exemption #11639, the FAA has found that the enhanced safety achieved using an UAS 

with the specifications described herein, and carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that such exemption is in the public 
interest. Since we are applying at a time when the FAA is using a “summary grant 

process” be informed that while developing this request we reviewed, among others, 

exemptions #11636, #11639, #11595, #11596, #11564, #11569, and #11616.

Extent of Relief and Reason for Seeking Relief; Why the Exemption 

would not Adversely Affect Safety, or How the Exemption would 

Provide a Level of Safety Equal to Existing Rule

Part 21 Airworthiness Certification; Subpart H Certification procedures and parts, 

Airworthiness Certificates

This section outlines requirements for the issue of design and production approvals, 

airworthiness certificates, and other airworthiness approvals. We seek relief from this 

rule because the size, weight and enclosed operational area of our UAS, as described 

elsewhere in this document, permit exemption from Part 21 because our UAS meet and 

exceed an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA 

is authorized to exempt aircraft from the airworthiness certificate requirement under both 

the Act (49. U.S.C. §44701(f)) and Section 333 of the Reform Act. Therefore, relief from 

14 CFR part 21, and any associated noise certification and testing requirements of part 

36, is not necessary.

Instead of following this requirement, we will as outlined in this document, as per our 

Flight Operations and Procedures Manual and Training Manual (currently in 

development), Digital-Hover seeks to uphold the same level or exceeded level of safety 

as described in Part 21 of 14 C.F.R. Therefore this exemption will not adversely affect 

safety or will provide a level of safety equal to the existing rule.

14 CFR 45.23 Display of Marks

This section outlines regulations requiring specific location(s) and size of aircraft marks. 

We seek relief from this rule because, given the size of our UAS, and the lack of cabin, 

cockpit or pilot station, two-inch lettering is difficult to place on such small aircraft.

Instead of following this requirement, we will mark the UAS in lettering that is as large 

as practicable by placing an N number registered with the FAA on its fuselage so that the 

PIC, VO, or other observers will see the markings. This exemption will therefore not 

adversely affect safety or will provide a level of safety equal to the existing rule.

14 CFR 61.113(a) & (b) Private Pilot Privileges and Limitations

This section describes regulations concerning certification of pilots. We seek relief from 

this rule because the risks associated with the operation of a UAS are lesser than and 

often uncorrelated with the risks associated with the commercial and private aircraft 

operations contemplated by Part 61 when drafted. The skills required to fly large, manned 

aircraft are substantially different from the skills required to remotely operate a small 

UAS. Also, manned aerial vehicles weighing significantly more than small drones (such 

as ultralight vehicles) as well as small UAS legally operated by hobbyists, operate

without the need for pilot certification.
Requiring a private or commercial pilot certificate would provide no appreciable safety 

benefit and would needlessly impose an undue burden of time and cost on Digital-Hover, 

most particularly in light of the FAA’s Small UAS Notice of Proposed Rulemaking 

which proposes that small UAS pilots be considered ‘operators’ required to meet certain 

requirements that do not include the pilot’s license.

Instead of following this requirement, to minimize risk and maximize safety, all UAS 

operations will be controlled and limited, and all flights will be planned and coordinated 

prior to operations:

 Prior to operations, Digital-Hover PIC(s) will go through a documented process of 

dedicated ground school and flight lessons in accordance with manufacturer and 

industry guides.

 All PIC’s will only operate the UAS as stated in this document and in our Flight 

Operations and Procedures Manual, flying at altitudes well below the permissible 

limits for other civil aircraft, and within a geographical envelope under the control 

of Digital-Hover clients.

 The PIC will be designate before a flight and will not transfer control at any time 

during a flight.

 Digital-Hover PIC’s will comply with upcoming FAA Operator Certification and 

Responsibilities once they are finalized.

This exemption will therefore not adversely affect safety or will provide a level of safety 

equal to the existing rule. More information about pilot safety can be found in the 

Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property

section of this document.

14 CFR 91.105 Flight crewmembers at stations

This section outlines regulations for flight crewmembers inside an aircraft. We seek relief 

from this rule because there is no flight crew onboard a small UAS.

Instead of following this requirement, in keeping with the direction of the regulation, the 

PIC of the UAS and VO will be at their respective crewmember stations on the ground 

during takeoff and landing as well as the complete duration of the flight. By instituting 

this procedure this exemption will therefore not adversely affect safety or will provide a 

level of safety equal to the existing rule.

14 CFR 91.109(a) Flight Instruction

This section provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. We seek relief from this rule because UAS do not have fully functioning 

dual controls.

Instead flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight 
instruction in experimental aircraft. This exemption will therefore not adversely affect 

safety or will provide a level of safety equal to the existing rule.

14 CFR 91.119(c) Minimum safe altitudes: General

This section establishes minimum altitudes for operation of civil aircraft. We seek relief 

from this rule because the services we intend to provide for the public good may require 

photo or video images captured from an altitude of less than 500 feet.

Instead of following this requirement, all UAS flights will be conducted within visual line 

of sight and with prior permission from the owner of the property or municipality. All 

persons, vessels, vehicles, not directly involved with the operation will be notified and 

cleared of the area where UAS operations will be conducted. Given our policies of 

advance notice and access restricted area, and given the size, weight, maneuverability and 

speed of our UAS, we will maintain an equivalent or higher level of safety of that 

described in this rule.

14 CFR 91.121 Altimeter settings

This section defines the regulations for altimeter settings. We seek relief from this rule 

concerning altimeter settings because: our UAS has no altimeter settings. Instead, 

electronic GPS downlinks telemetry data in real time to the PIC’s ground-based onscreen display as to the altitude (AGL) of the UAS above the takeoff location.

This exemption will not adversely affect safety, as our PIC will provide a level of safety 

equal to the existing rule by confirming the altitude of the launch site shown on the GPS 

altitude indicator prior to each flight.

14 CFR 91.151(a) Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing, and, assuming normal cruising speed – (1) 

During the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for 

at least 45 minutes.” We seek relief from this rule because our UAS runs on battery

instead of fuel, most of our UAS flight last less than the 30 minute reserve requirement, 

and we do not fly at night.

Instead of following this requirement, an equivalent level of safety will be achieved by 

following the UAS manufacturer’s documents with regard to battery voltage. To ensure 

safety and maintain adequate communication between radio control and the UAS, our 

PIC will not begin a flight with a battery holding less than 75% charge; and will not 

begin a flight unless (considering wind and forecast weather conditions) there is enough 

power to fly to the intended landing point at normal cruising speed and land the UAS 

with no less than 30% of battery power. A landing sequence at 15% charge while still 

under PIC control.
Through implementation of these procedures, this exemption will not adversely affect 

safety or will provide a level of safety equal to the existing rule.

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

This regulation pertains to display of airworthiness certification within an aircraft. We 

seek relief from this rule because our small UAS each weigh less than 10 pounds, and are 

operated without an onboard pilot. There are passengers or crew; and no cabin or cockpit 

entrance upon which to display certificates.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the PIC will have immediate access to them, and be able to provide 

them upon request.

14 CFR 91.405(a) Maintenance required; 14 CFR 91.407(a)(1) Operation after 

maintenance, preventative maintenance, rebuilding, or alteration; 14 CFR 

91.409(a)(2) Inspections; and 14 CFR 91.417(a) & (b) Maintenance records

We seek relief from these 4 rules because these regulations only apply to aircraft with an 

airworthiness certificate, and will not, therefore apply to Digital-Hover’s UAS. We seek 

relief also because the FAA has not developed maintenance standards for UAS that 

would allow an UAS operator to meet the part 91 maintenance requirements. In 

particular, there are no individuals authorized by the FAA to approve a UAS for return to 

service or to conduct the initial airworthiness and annual return to service inspections as 

required.

Instead of following these requirements, we will:

 Perform preventative and required maintenance on each aircraft as per the 

owner’s manuals.

 Inspect our UAS before and after each flight as per our Flight Operations and 

Procedures Manual to ensure that the UAS is in a condition for safe flight

 Will conduct a test flight on each aircraft following any major repairs

 Will properly note all discrepancies, maintenance, and alterations in a 

Maintenance Log

Therefore this exemption would not adversely affect safety or would provide a level of 

safety equal to the existing rule. More information about maintenance procedures can be 

found in the Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People 

and Property section of this document.

14 CFR 91.7(a) Civil aircraft airworthiness

This section states that “no person may operate a civil aircraft unless it is in an airworthy 

condition.” We seek relief from this rule based on the fact that Digital-Hover’s UAS will 

not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. 

Based on the fact that an airworthiness certificate will not be issued, exemption from 

§91.7(a) is not necessary.
An equivalent level of safety will be achieved through the guidance from our Flight 

Operations and Procedures Manual, pilot training, and operational risk management for 

each activity.

14 CFR 91.9(b) Civil aircraft flight manual, marking, and placard requirements

This section requires an aircraft flight manual in the aircraft. We seek relief from this rule 

based on the small size of our UAS and the fact that our UAS carries no onboard pilots or 

passengers. Given its size and configuration there is no room or capacity in our UAS to 

carry such an item. This regulation is therefore inapplicable.

An equivalent level of compliance will be achieved by keeping our versions of these 

documents at the ground control point where the PIC will have immediate access to them, 

and be able to provide them upon request.

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Public Benefit: How our request would benefit the public as a whole

Granting Digital-Hover the ability to operate a small UAS safely and legally in the 

National Airspace System will have the following positive economic and societal impacts

on local communities, businesses, organizations, and community members:

 Benefit local business marketing by offering state-of-the-art aerial photography

and videography

 Help to inspect buildings and structures, and map landscapes in a safe, costeffective manner

 Provide economic stimulus and public benefit by providing an effective means by

which companies or individuals looking to relocate to an area can use up-to-date, 

high-quality photos and videos of real estate properties to learn about properties, 

neighborhoods, and communities

 Help communities realize economic benefit by encouraging public participation 

and encouraging tourism by showcasing community buildings and landscapes and 

by documenting community events in low-cost ways not previously available to 

them

 Increase awareness/knowledge of the amenities of a local area by the general 

public and by visiting tourists

 Provide non-profit organizations as well as schools and universities and local 

municipalities ways to showcase facilities, document events, and educate the 

public

 Aid in search and rescue operations and accident investigators

All of the above services:

 Are otherwise unavailable to the public, given the UAS’s the ability to:

o Safely capture images from 0 to 400 feet

o Create images that are more up-to-date and more closely defined that 

Google Earth-type satellite images
o Create images at prices lower than that of traditional helicopter and 

airplane photography and videography

 Increase safety of and reduce risk to the public and the NAS by:

o Replacing large manned helicopter and airplane flights with small UAS 

flights, thereby reducing air and noise pollution as well as the dangers 

inherent in flying aircraft loaded with crewmembers and combustible fuel 

close to people and property

o Offering safer ways to inspect tall structures and remote locations, e.g. 

removing the physical risk of climbing on a roof or structure to inspect it

 Reduce environmental pollution and reliance on fossil fuels by replacing fueled 

aircraft flights with battery-operated UAS flights

Operation of the Unmanned Aircraft to Minimize Risk to the NAS, 

People, and Property

Concerning our commercial UAS flight operations, we take seriously our obligation to 

clearly define operational borders, and implement operational risk management 

procedures to ensure the public safety of persons and property both in the air and on the 

ground.

While Digital-Hover currently provides photography and videography services in the 

northern portion of Texas, we may at times contract with clients throughout the U.S. Our 

area of intended operations include a range of population areas, from urban to rural, with 

some areas experiencing seasonal increases and decreases in activity from both people 

and aircraft. Our operations will take into account these variations in populations and 

activities. My experience in navigation, weather observation and small aircraft 

operations, enable me to apply operational risk management techniques when assessing 

situations where the safety of the general population and the NAS are concerned.

Meeting or exceeding COA requirements to perform commercial operations in low-risk, 

controlled environments, our UAS will be operated:

 During daytime Visual Flight Rules (VFR) conditions and visual meteorological 

conditions (VMC)

 Within visual line of sight (VLOS) of the Pilot in Command (PIC) or the Visual 

Observer (VO), in accordance with the statutory Section 333(b)(1) mandate.

 In such a manner that the PIC and VO are able to communicate verbally at all 

times; and that the VO can assist the PIC while seeing and avoiding other air 

traffic and other ground-based obstacles/obstructions.

We will not operate our UAS:

 At altitudes exceeding 400 feet AGL

 In winds exceeding 25 knots

 From any moving vehicle or device

 At airspeeds greater than the maximum recommended by the manufacturer
 Less than 500 feet below or less than 2000 feet horizontally from a cloud or when 

visibility is less than 3 statute miles from the PIC

 Unless (considering wind and forecast weather conditions) there is enough 

available power from the UAS to conduct the intended operation and to operate 

after that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater.

 Near areas where the general public is within 200 feet; or directly over any person 

except authorized Digital-Hover personnel and consenting inspection personnel, 

unless operations nearer to the PIC do not present an undue hazard to those 

persons; or unless the owner/controller of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined 

that it does not present an undue hazard.

 Near power lines or elevated lights; or within areas of airspace restrictions such as 

the one imposed by the National Park Service

 Near airports, heliports, or military bases; more specifically:

o In accordance with the statutory section 333 mandate regarding proximity

to airports, we will stay certain distances away from airports or heliports: 

5 NM from an airport having an operational control tower; or 3 NM from 

airport w/ a published instrument flight procedure, but not operational 

tower; or 2 NM from an airport w/out published instrument flight 

procedure or an operational tower; or 2 NM from a heliport with a 

published instrument flight procedure

o We will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or 

for airports not denoted with an ARP, the center of the airport symbol as 

denoted on the current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management will be made available to the 

Administrator or any law enforcement official upon request.

 If we intend to conduct operations in controlled airspaces which have existing 

requirements to notify Flight Standards District Offices (FSDOs) prior to 

operations – such as motion picture and television filming, or pipeline and 

powerline patrol – we will contact the local FSDO and comply with their 

procedures, such as filing a NOTAM as per their request.

Our Flight Operations and Procedures Manual, will include procedures for:

 Conducting a preflight safety risk assessment to determine that the UAS is in a 

condition for safe flight, i.e. completing a preflight inspection checklist to ensure 

the UAS’s airworthiness. If the inspection reveals a condition that affects the safe 

operation of the UAS and/or the Ground Control Station, the aircraft will be 

prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight.

 Maintaining a Flight Log (noting UAS flight time, Control Unit operation time, 

incident reports, etc.); and making said Log available to the FAA if requested
 Conducting initial and ongoing training of PICs and VOs on a regular basis

 Maintaining and repairing the aircraft to ensure that it is in a condition for safe 

operation by:

o Following the UAS manufacturer’s maintenance, overhaul, replacement 

inspection, and life limit requirements and safety bulletins for the aircraft 

and its components

o Installing firmware updates provided by the manufacturer

o Keeping a Maintenance Log noting all maintenance, inspection, 

alterations, and status of replacement/overhaul component parts in the 

aircraft records, including total time in service, description of work, and 

signature of the authorized person returning the UAS to service; and 

making said Log available to the FAA if requested

o Verifying condition of flight batteries and calibrating the Inertial 

Measurement Unit (IMU) using manufacturer software

o Conducting a functional test flight on any UAS that has undergone 

maintenance or alterations that affect the UAS operation; said functional 

test flight will be conducted by a PIC with a VO and so as to not pose an 

undue hazard to persons and property; and recorded in the aircraft records

 Procedures that ensure that the planned operation can be completed safely, such 

as:

o Checking local sectional (air) charts, notam (notice to airmen), etc. prior to 

the flight

o Conducting pre-flight visual survey of the area to consider characteristics 

of the area of intended operation(s) and the associated potential hazards 

regarding proximity to populated areas

o Remaining clear and giving way to all manned aviation operations and 

activities at all times

o Aborting a flight and landing the UAS at the nearest and safest ground

point in the event of safety breaches, potential danger, unpredicted 

obstacles or emergencies

o Using a fresh, fully charged battery with each flight as a safety precaution, 

to ensure safety and maintain adequate communication between radio 

control and the UAS; and not operating our UAS at or below manufacturer 

recommended minimum charge levels for operation

Also:

 Flight operations will be performed only at the request of and with the 

authorization and permission of clients (property owner/controller) or their 

authorized representatives

 Caution signs will be placed at the site of aerial operations to warn people that 

aircraft operations are in progress

 Our Client Agreements will reserve us the right to decline a photo shoot if 

conditions of the location (i.e. proximity of power lines) may cause unacceptable 

risk; and to reschedule a photo shoot if weather conditions such as precipitation or 

wind speed become a factor
 The operating documents for our UAS, and any revisions, will be accessible 

during UAS operations and made available to the Administrator or law 

enforcement official upon request

 We carry comprehensive general liability insurance coverage and an additional 

insurance policy specifically covering our UAS

Summary for Federal Register

James G. Compton of Digital-Hover LLC, Amarillo, Texas seeks exemption from 

Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA 

Modernization and Reform Act of 2012 for the purpose of commercially operating small 

Unmanned Aircraft Systems (UAS) safely and legally in the National Airspace System.

Specifically, Digital-Hover seeks relief from the following sections of the current 

regulations: 14 CFR 21 subpart H – Certification procedures; Airworthiness Certificates; 

14 CFR 45.23 – Display of Marks; 14 CFR 61.113(a) & (b) Private Pilot Privileges and 

Limitations; 14 CFR 91.105 Flight crewmembers at stations; 14 CFR 91.109(a) Flight 

Instruction; 14 CFR 91.119(c) Minimum safe altitudes; 14 CFR 91.121 – Altimeter 

settings; 14 CFR 91.151(a) – Fuel Requirements for Flight in VFR Conditions; 14 CFR 

91.203 Carrying Civil Aircraft Certification and Registration; 14 CFR 91.405(a) 14 CFR 

91.409(a)(2) Maintenance required; Operation after maintenance, preventative 

maintenance, rebuilding or alteration; 14 CFR 91.417(a)&(b) Maintenance Records; 14 

CFR 91.7(a) – Civil Aircraft Airworthiness; 14 CFR 91.9(b) Civil aircraft flight manual, 

marking, and placard requirements.

Digital-Hover intends to use small UAS to provide aerial photography and videography 

services to businesses, organizations, and community members. More specifically, we 

intend to:

 Enable businesses to benefit through the use of state-of-the-art visual marketing 

materials

 Help inspect buildings and structures, and map landscapes in a safe, cost-effective 

manner 

 Provide economic stimulus and public benefit by providing an effective means by 

which companies or individuals can use up-to-date, high quality photos and 

videos to learn about properties, neighborhoods, and communities

 Help communities realize economic benefit by encouraging public participation 

and encouraging tourism; by showcasing community buildings and landscapes; 

and by documenting community events in low-cost ways not previously available 

to them

 Increase awareness/knowledge of the amenities of a local area by the general 

public and by visiting tourists

 Provide non-profit organizations as well as schools and universities and local 

municipalities ways to showcase facilities, document events, and educate the 

public

 Aid in search and rescue operations and accident investigators
The enhanced safety achieved using an UAS with the specifications described herein, and 

carrying no passengers or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel, should give the FAA good 

cause to find that such exemption is in the public interest. By granting this request for 

exemption, the FAA will facilitate the smooth integration of UAS into the NAS.

Additional Information

Design characteristics, Aircraft Performance and Performance 

Limitations, and Conditions of the UAS to be Operated

Both of the UAS described below:

 Utilize 4 counter-rotating propellers for balance, control, and stability

 Are equipped with GPS to maintain geospatial orientation and position

 Use Return Home safety technology and Auto Landing feature if UAS loses 

transmitter signal

 Are controlled primarily through FCC approved RF spectrum 

transmitter/controller/receivers; and FCC approved RF spectrum EIRP with 

transmitting power of 100 mW for dedicated wifi transmitter/receiver between 

UAS, Range Extender attached to transmitter and mobile viewing device 

displaying operational telemetry and video/photography functions

 Send real time video and telemetry information is transmitted back to a ground 

control station, allowing PIC to monitor battery level, GPS signal strength, 

altitude (AGL), distance from PIC, camera imagery, and control camera angle

 Have failsafe modes of operation for either loss of RC or GPS signal. Altitude can 

be limited by the onboard flight controller and maximum altitude can be 

preprogrammed by the PIC

 Have audible and visual sequential low battery warnings set at 30% charge and 

15% charge remaining. The UAS automatically initiates landing sequence at 15% 

charge while still under PIC control. The onboard flight controller will warn the 

pilot via telemetry and external lighting cues before reaching a low battery state. 

An automatic termination of flight and landing will be initiated when the battery

reaches a predetermined low state

DJI Phantom 3 Professional

 Gross weight of less than 3 pounds including camera and battery

 Cruising speed of 15 knots, with a maximum speed of 31 knots and maximum 

altitude of 6000 m

 Maximum flight time of 23 minutes

 FCC compliant Radio Frequency (RF) spectrum 2.400 GHz-2.483 GHz

 Manual available at http://www.dji.com/product/phantom-3/download

DJI Matrice 100

 Gross weight of less than 3 pounds including camera and battery

 Cruising speed of 15 knots, with a maximum speed of 30 knots and maximum 

altitude of 5000m
 Maximum flight time of 45 minutes

 FCC compliant Radio Frequency (RF) spectrum 2.400 GHz-2.483 GHz

 Manual available at https://developer.dji.com/matrice-100/downloads/